ML100560345
| ML100560345 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 03/08/2010 |
| From: | Leeds E Office of Nuclear Reactor Regulation |
| To: | Robinson T Citizen Power |
| Plasse, Richard 301-415-1427 DLR/RPB2 | |
| Shared Package | |
| ML100640700 | List: |
| References | |
| EDATS: NRR-2010-0010, TAC ME3056, TAC ME3057, Y020100008 | |
| Download: ML100560345 (2) | |
Text
March 8, 2010 Mr. Theodore Robinson, Esq.
Citizen Power 2121 Murray Avenue Pittsburgh, PA 15217
Dear Mr. Robinson:
On behalf of the U.S. Nuclear Regulatory Commission (NRC or the staff), I am responding to your letter dated December 31, 2009 (Agencywide Documents Access and Management System (ADAMS) Accession Number ML100150207), expressing your concern regarding the inspection program to be implemented by FirstEnergy Nuclear Operating Company (FENOC) at the Beaver Valley Power Station (BVPS), Units 1 and 2, to identify corrosion of the containment liner that originates from the outside surface of the liner.
Your letter was in response to the NRCs letter dated October 24, 2009 (ADAMS Accession Number ML092230728). As described in that letter, the staff considers the degradation of the containment liner plate an important issue since the liner plate, in conjunction with the concrete behind the liner, provides an essentially leak-tight pressure barrier during all postulated accident conditions. The staffs evaluation of FENOCs proposed actions is addressed in Safety Evaluation Report Related to the License Renewal of the Beaver Valley Power Station, Units 1 and 2, which was issued on June 8, 2009 (ADAMS Accession Number ML091600216). In addition, the staff issued Supplement 1 to the BVPS, Units 1 and 2, Safety Evaluation Report (SER), dated October 6, 2009 (ADAMS Accession Number ML092520531), which evaluates supplemental information provided by FENOC related to their liner inspection program. Based on the staffs evaluation described in the supplement to the SER, the staff has concluded that the commitments made by the applicant for the visual and volumetric examinations of the liner plate are acceptable and provide reasonable assurance that the containment liner plate at BVPS, Units 1 and 2, will continue to remain functional during the period of extended operation.
We appreciate the comments provided in your letter dated December 31, 2009. Below are specific responses to some of the items that you addressed in your letter:
- 1. Regarding your comment that we did not respond to the second issue in your letter dated August 27, 2009 (ADAMS Accession Number ML092460728) related to the suitability of the Integrated Leak Rate Test (ILRT) to detect containment liner corrosion on the outside of the liner, we would like to clarify our prior response. Although the ILRT does not provide specific information on the condition of the outer surface of the containment liner, a successful ILRT does provide assurance, as a defense-in-depth indication, that the whole containment system (steel liner and 54-inch thick concrete) is functioning as intended, consistent with regulatory requirements.
- 2. Regarding your comment that the NRC had previously rejected use of Electric Power Research Institute Technical Report (TR) TR-107514 in the North Anna/Surry SER of December 2002 because it had not been reviewed or approved by the staff, the staff has
developed experience using this report in various applications, and we have confidence that the methodology in the report, appropriately adjusted using a 95/95 confidence criterion as described in Supplement 1 to the BVPS, Units 1 and 2, SER (ADAMS Accession Number ML092520531), will adequately characterize the condition of the containment liner.
- 3. Regarding your comments on the inspection findings that are attributable to fabrication/erection, such findings would include geometric features such as thickness changes that are attributable to plate thickness mismatches, and grinding or welding artifacts, and would not include indications of true degradation from corrosion, pitting or other aging-related effects. Any findings that are aging related would be classified as a failure in the statistical analysis and would be appropriately considered in the sampling program.
- 4. Regarding your comments on the sampling occurring over a period of time and the need for adjustment to the results, the timing of the inspections provides benefits that would outweigh any need for adjustments. As opposed to a delayed sampling approach with all sampling at one time, there is the benefit of early detection for those areas that may be experiencing degradation and are sampled early. As opposed to an early sampling approach with all sampling at one time, there is an increased likelihood of detecting degradation because of the increased time that such degradation (in the unlikely event that it is occurring) would have to manifest itself in a detectable condition. Therefore, the sampling over a period of time, including both random and non-random samples as described in Supplement 1 to the BVPS, Units 1 and 2, SER, provides benefits over concentrating the sampling at one time. In all cases should aging-related degradation be identified, we expect the utility to reassess their sampling schedule and plan (e.g.,
number of areas to be sampled), consistent with their Corrective Action Program; we will oversee these activities through NRC inspection follow-up.
In summary, the staff has reviewed your comments and has concluded that no changes to the conclusions in our safety evaluation are necessary. Note that the NRC staff will brief the Advisory Committee on Reactor Safeguards (ACRS) on current staff efforts to address the generic aspects of containment liner corrosion in a future meeting. We anticipate that this briefing will cover a variety of containment designs and operating experience, including that of Beaver Valley. Meetings of the ACRS are typically open to the public and are noticed on NRCs webpage at http://www.nrc.gov/reading-rm/doc-collections/acrs/agenda/2010/. We will ensure that you are contacted once this meeting has been publically noticed.
Sincerely,
/RA by Bruce Boger for/
Eric J. Leeds, Director Office of Nuclear Reactor Regulation cc: See next page
ML100640700 (Package); ML100151704 (Incoming); ML100560345 (Response)
OFFICE PM:RPB2:DLR LA:DLR BC:RPB2:DLR SL:DLR BC:RASB:DLR*
NAME RPlasse IKing(YEdmonds for)
DWrona AHiser RAuluck DATE 03/01/10 03/05/10 03/01/010 03/01/10 03/01/10 OFFICE BC:EMCB:DE*
BC:RI*
D:DLR D:NRR NAME MKhanna RConte BHolian ELeeds(BBoger for)
DATE 03/05/10 03/05/10 03/05/10 03/08/10
Letter to T. Robinson from E. Leeds dated March 8, 2010
SUBJECT:
CITIZEN POWER QUESTIONS REGARDING FENOC INSPECTION PROGRAM TO IDENTITY CORROSION OF THE CONTAINMENT LINER AT BEAVER VALLEY DISTRIBUTION: Y020100008/EDATS: NRR-2010-0010 HARD COPY:
DLR RF E-MAIL:
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Beaver Valley Power Station, Units 1 and 2 cc:
Joseph J. Hagan President and Chief Nuclear Officer FirstEnergy Nuclear Operating Company Mail Stop A-GO-19 76 South Main Street Akron, OH 44308 James H. Lash Senior Vice President of Operations and Chief Operating Officer FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308 Danny L. Pace Senior Vice President, Fleet Engineering FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308 Jeannie M. Rinckel Vice President, Fleet Oversight FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308 Paul A. Harden Vice President, Nuclear Support FirstEnergy Nuclear Operating Company Mail Stop A-GO-14 76 South Main Street Akron, OH 44308 David W. Jenkins, Attorney FirstEnergy Corporation Mail Stop A-GO-15 76 South Main Street Akron, OH 44308 Manager, Fleet Licensing FirstEnergy Nuclear Operating Company Mail Stop A-GO-2 76 South Main Street Akron, OH 44308 Director, Fleet Regulatory Affairs FirstEnergy Nuclear Operating Company Mail Stop A-GO-2 76 South Main Street Akron, OH 44308 Manager, Site Regulatory Compliance FirstEnergy Nuclear Operating Company Beaver Valley Power Station Mail Stop A-BV-A P.O. Box 4, Route 168 Shippingport, PA 15077 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 298 Shippingport, PA 15077 Cliff Custer FirstEnergy Nuclear Operating Company Beaver Valley Power Station P.O. Box 4, Route 168 Shippingport, PA 15077 Steve Dort FirstEnergy Nuclear Operating Company Beaver Valley Power Station P.O. Box 4, Route 168 Shippingport, PA 15077 Mike Banko FirstEnergy Nuclear Operating Company Beaver Valley Power Station P.O. Box 4, Route 168 Shippingport, PA 15077